1. Background

1.1 instalppi, with its registered office at UK, and other companies in the instalppi group collect and use certain personal data (as defined below). instalppi is responsible for ensuring that it uses that personal data in compliance with data protection laws.

1.2 At instalppi, we respect the privacy of our clients and are committed to keeping all your personal data secure. This Privacy Policy governs the handling of personal data by instalppi in the course of our commercial activities.

1.3 Definitions used in this Privacy Policy:

• (A) Customer: A publisher who owns/controls/operates Internet assets (such as websites) ("Publisher Assets") and incorporates instalppi products in their assets ("Publisher"), or an advertiser who provides us with content to be served through instalppi products and/or Publisher assets ("Advertiser"), or with whom instalppi has a contractual relationship.
• (B) Personal Data: Any data that relates to a living individual who can be identified from that data or from that data and other information in the possession of, or likely to come into the possession of, instalppi (or its representatives or service providers). This includes any expression of opinion about an individual and any indication of the intentions of instalppi or any other person in respect of an individual.
• (C) instalppi and other companies in the instalppi group.
• (D) www.instalppi.com or any other instalppi website displaying this Privacy Policy.
• (E) User: A person making any use of the instalppi website and/or instalppi products.

2. The Products and Services We Provide

2.1 This Privacy Policy concerns the following categories of information that we collect about the User when providing the following products and services:

• (A) Information we receive through our websites ("instalppi Websites");
• (B) Information we receive through our products ("instalppi Products");
• (C) Information we receive through our support or cloud-based services ("instalppi Services").

2.2 Personal Data may be collected from (a) instalppi Websites, for example with respect to personnel of our Customers engaging us through the instalppi Website; (b) instalppi Products, for example when a User interacts with Publisher assets.

3. The Types of Personal Data We Collect

Many of the services offered by instalppi require us to obtain personal data about a User in order to perform the services we have been engaged to provide. In relation to each of the services described in Section 2.1 above, we will collect and process the following personal data about Users:

3.1 Information that a User provides to instalppi. This includes information about Users that they provide to us. The nature of the services Users are requesting will determine the kind of personal data we might ask for, which may include (by way of a non-exhaustive list):

• (A) Basic personal data (such as first name, family name, position in the company, company name, company email address, business phone number, business address, city, postcode, country);
• (B) Any information that a User chooses to share on instalppi internet forums, which may be considered personal data. (Please note that instalppi does not collate information included on instalppi internet forums together with personal data from a User Center account or profile).

3.2 Information that we collect or generate about Users. This includes (by way of a non-exhaustive list):

• (A) A file with Users’ contact history to be used for enquiry purposes so that we may ensure that Users are satisfied with the services which we have provided to them;
• (B) Information on the internet usage or browsing habits of Users of Publisher Assets (e.g., what websites or pages were visited by each User, any advertisements viewed by Users, and resulting actions such as visits to other websites);
• (C) The internet browser used, the internet device operating system and device ID, IP address (from which geo location may be extracted to a level of a city).

3.3 Information we obtain from other sources.

• (A) Cookies: When Users visit instalppi Websites, use instalppi Products, and/or Publisher Assets, cookies are used to collect technical information about the services that they use and how they use them. For more information on the cookies used by instalppi, please see our Cookie Notice.
• (B) Anonymized data: In addition to the categories of personal data described above, instalppi will also process further anonymized information and data that is not processed by reference to a specific individual.

3.4 Information we get from third parties: The information we collect comes mainly directly from Users or as a result of Users’ browsing habits. Sometimes we might collect personal data about Users from other sources, such as publicly available materials or trusted third parties like our marketing and research partners. We use this information to supplement the personal data we already hold about Users, in order to better inform, personalize, and improve our services, and to validate the personal data Users provide.

3.5 Advertisers: We may also use third parties such as network Advertisers, which are third parties that display advertisements based on Users’ visits to websites they have visited to target advertisements for products and services in which Users might be interested. Third-party ad network providers, Advertisers, sponsors, and/or traffic measurement services may also use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs, and other technologies to measure the effectiveness of their ads and to personalize advertising content for Users. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one.

4. How We Use Users’ Information

4.1 The purposes for which we use personal data and the legal basis for such processing include (by way of a non-exhaustive list):

• (A) To provide Users with products and services, pursuant to our contractual relationship;
• (B) To engage in transactions with customers, suppliers, and business partners and to process orders for instalppi products and services;
• (C) To facilitate access to and use of the instalppi Website;
• (D) To respond to User inquiries;
• (E) To provide technical support;
• (F) To provide Users with effective advertising and marketing messages;
• (G) To improve our products and services;
• (H) For security and fraud prevention; and
• (I) To comply with legal obligations.

4.2 We may use personal data to contact Users with information about instalppi’s products and services, and other information that may be of interest to Users, including information about services or products from third parties. Such communications may be sent using the contact details Users have provided to us and depending on applicable law Users may be required to “opt in” or “opt out” of receiving such communications.

5. Disclosure of Users’ Information to Third Parties

5.1 We may share Users’ personal data within instalppi and other companies in the instalppi group.

5.2 We may also share Users’ personal data outside of the instalppi group:

• (A) With our business partners. For example, this could include our partners from whom Users or their companies or organizations purchase services. Personal data will only be shared with these business partners when strictly necessary to fulfil an order for products or services or to provide other services or information to Users.
• (B) With third-party service providers, for example, IT services or other services to help process Users’ personal data for the purposes described above;
• (C) With third parties involved in hosting or organizing events or seminars;
• (D) In the event that we sell or buy any business or assets, in which case we may disclose personal data to the prospective seller or buyer of such business or assets;
• (E) If instalppi or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
• (F) If we are under a duty to disclose or share personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

6. International Transfers of Personal Data

6.1 instalppi is a global business and Users’ personal data may be transferred across national borders, including to countries outside the European Economic Area (EEA) for the purposes described in this Privacy Policy.

6.2 When we transfer Users’ personal data outside of the EEA to other members of the instalppi group or to third-party service providers, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information. This can be done in a number of different ways, for example:

• (A) The country to which we send the personal data might be approved by the European Commission as offering a sufficient level of protection;
• (B) The recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect the personal data;
• (C) In other circumstances, the law may permit us to otherwise transfer Users’ personal data outside the EEA.

6.3 Users can obtain more details of the protection given to their personal data when it is transferred outside the EEA (including a sample copy of the standard data protection clauses which we have entered with recipients of Users’ personal data) by contacting us as described in Section 10 below.

7. How We Safeguard Users’ Information

7.1 We have extensive controls in place to maintain the security of our information and information systems. Files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where personal data is gathered, processed, or stored is limited to authorized employees.

7.2 As a condition of employment, instalppi employees are required to follow all applicable laws and regulations, including in relation to data protection law. Unauthorized use or disclosure of confidential client information by an instalppi employee is prohibited and may result in disciplinary measures.

7.3 When Users contact a instalppi employee about their file, they may be asked to provide some personal details for identification purposes. This type of safeguard is designed to ensure that only Users, or someone authorized by Users, have access to their file.

8. How Long We Keep Users’ Personal Data

8.1 How long we will hold Users’ personal data for will vary. The retention period will be determined by various criteria including:

• (A) The purpose for which we are using it – instalppi will need to keep the data for as long as is necessary for that purpose; and
• (B) Legal obligations – laws or regulation may set a minimum period for which we have to keep Users’ personal data.

9. Users’ Rights

9.1 In all the above cases in which we collect, use, or store Users’ personal data, Users may have the following rights, and in most cases, Users can exercise them free of charge. These rights include:

• (A) The right to obtain information regarding the processing of Users’ personal data and access to the personal data which we hold about Users;
• (B) The right to withdraw their consent to the processing of their personal data at any time. Please note, however, that we may still be entitled to process Users’ personal data if we have another legitimate reason for doing so. For example, we may need to retain personal data to comply with a legal obligation;
• (C) In some circumstances, the right to receive some personal data in a structured, commonly used, and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which Users have provided to us;
• (D) The right to request that we rectify Users’ personal data if it is inaccurate or incomplete;
• (E) The right to request that we erase Users’ personal data in certain circumstances. Please note that there may be circumstances where Users ask us to erase their personal data but we are legally entitled to retain it;
• (F) The right to object to, and the right to request that we restrict, our processing of Users’ personal data in some circumstances. Again, there may be circumstances where Users object to, or ask us to restrict, our processing of their personal data but we are legally entitled to refuse that request; and
• (G) The right to lodge a complaint with the data protection regulator if Users think that any of their rights have been infringed by us.

10. Designated Representative

10.1 instalppi is headquartered in the United Kingdom. We have appointed a designated representative for data protection matters.

10.2 For any questions or concerns regarding this Privacy Policy or our data protection practices, please contact our Data Protection Officer at:

Email: [email protected]

Address: Instalppi Pvt Ltd, Data Protection Officer, UK.

11. Questions and Concerns

11.1 If Users have any questions or concerns about instalppi's handling of their personal data, or about this Policy, please contact our Data Protection Officer at:

Email: [email protected]

Address: Instalppi Pvt Ltd, Data Protection Officer, UK.

11.2 We are usually able to resolve privacy questions or concerns promptly and effectively. If Users are not satisfied with the response they receive from our Data Protection Officer, they may escalate their concern to the relevant supervisory authority in their jurisdiction.